Dr. Frank Colby is a scientist and researcher who began work for RJ
Reynolds in 1951 and has worked for RJ Reynolds ever since. Colby is currently
president of Frank G. Colby and Associates, a consulting company funded by R J
Reynolds.

Q. As you sit here today, do you believe that smoking has caused the
death of even one human being?

A. I told--I can regurgitate my saying again and again.

Q. I'm to repeat the question. As you sit here today, do you believe
that smoking has caused the death of even one human being?

A. Uh, probably there is one exception. Somebody uses his cigarette to
burn his, his home, but not from the point of [unintelligible] health,
no.

Q. And your position is the same as the tobacco industry's position,
correct?

Q. Objection.

A. My, my, my position is that the uh connections, allegations of the
connection between smoking and health are a matter of controversy. In other
words, it is probably no, but we can not deny the possibility it may, there may
be a connection. I mean, we regurgitate that for the 15th time. I don't think
there's any, any need for you--you cannot coerce me into, into lying or
whatever you can.

Texas v. American Tobacco Co.

December 19, 1997

Motley: "All right. But as far as lung cancer and emphysema, you,
Frank Colby, in 1997 do not believe that a single American has ever died from
lung cancer or emphysema caused by smoking cigarettes?"

Colby: "In and by itself."

Motley: "By itself, all right."

Colby: "By itself, the answer is no."

Motley: "Do you know who Jeffrey Bible is?"

Colby: "Yes. He is the Goldstone of Philip Morris."

Motley: "He is what?"

Colby: "The Goldstone of Philip Morris."

Motley: "He's the number one man of Philip Morris?"

Colby: "That is correct."

Motley: "Do you know agree or disagree with Mr. Bible who testified
when I questioned him that up to 100,000 Americans possibly die from lung
cancer caused by smoking every year?"